Comments, Reports & Amicus Briefs for 2013

These Section comments were submitted and cleared in accordance with ABA Blanket Authority Policy.  Please note that Blanket Authority is effective for two years from the date of submission, unless granted under “Expedited” procedure, in which case it is effective for 90 days from the date of submission.

  • Joint Comments of the American Bar Association's Sections of Antitrust Law and International Law to the Irish Competition Authority's Public Consultation on Merger Guidelines
    Cover LetterComments
    (October 2013)


  • Joint Comments of the American Bar Association's Sections of Antitrust Law and International Law on the European Commission's Public Consultation on Possible Improvements of the EU Merger Regulation
    Cover LetterComments
    (September 2013)


  • Joint Comments of American Bar Association's Sections of Antitrust Law and International Law Concerning the United Kingdom BIS Consultation Document
    Cover LetterComments
    (September 2013)


  • Joint Comments of the American Bar Association's Sections of Antitrust Law and International Law on the COMESA Draft Guidelines on Public Interest and Application of Articles 16 and 19 (Horizontal and Vertical Business Practices) and 18 (Abuse of Dominance)
    Cover LetterComments
    (August 2013)

  • Joint Comments of the American Bar Association's Sections of Antitrust Law and International Law on the Draft "Merger Review Process Guidelines" of the Australian Competition and Consumer Commission
    Cover LetterComments
    (August 2013)


  • Comments of the American Bar Association's Section of Antitrust Law on the Proposed Afghanistan Consumer Protection Law
    Cover LetterComments
    (July 2013)


  • Joint Comments of the American Bar Association's Sections of Antitrust Law and International Law on the European Commission's Draft Revision of Simplified Procedure and Merger Implementing Regulation
    Cover LetterComments
    (June 2013)

  • Joint Comments of the American Bar Association's Sections of Antitrust Law and International Law in Response to the COMESA Competition Commission's Request for Comments on the Proposed Draft Guidelines to the COMESA Competition Regulations, 2004
    Cover LetterComments
    (June 2013)


  • Joint Comments of the American Bar Association's Sections of Antitrust Law and International Law on Comisión Nacional de Competencia's Draft Revision of the Notice on Leniency
    Cover LetterComments
    (June 2013)


  • Joint Comments of the American Bar Association's Sections of Antitrust Law and International Law on the "Strategy Document" of the Netherlands Authority for Consumers and Markets
    Cover LetterComments
    (May 2013)

  • Joint Comments of the American Bar Association's Sections of Antitrust Law and International Law on the MOFCOM Draft Interim Regulation on Standards Applicable to Simple Cases of Concentrations of Business Operators
    Cover LetterComments (in Chinese, English)
    (May 2013)

  • Joint Comments Of The American Bar Association's Sections Of Antitrust Law, Intellectual Property Law, International Law, And Science & Technology Law On The European Commission Draft Proposal For A Revised Block Exemption For Technology Transfer Agreements And For Revised Guidelines
    Cover LetterComments
    (May 2013)


  • Joint Comments of the American Bar Association's Sections of Antitrust Law and International Law on Ministry of Commerce Draft Regulations Regarding the Imposition of Restrictive Conditions for Concentrations of Business Operators
    Cover LetterComments (in Chinese, English)
    (May 2013)


  • Joint Comments of the American Bar Association's Sections of Antitrust Law and International Law in Response to the Mexican Competition Commission's Request for Comments on the Proposed Regulation Implementing the Mexican Federal Competition Law
    Cover LetterComments
    (April 2013)


  • Presidential Transition Report on the State of Antitrust Enforcement 2012
    Cover LetterComments
    (February 2013)


  • Comments of the American Bar Association's Section of Antitrust Law in Response to the Federal Trade Commission's Request for Public Comment Regarding its Guides for Advertising Allowances and Other Merchandising Payments and Services (the "Fred Meyer Guides")
    Cover LetterComments
    (January 2013)


  • Report of the Task Force on Controlling Costs of Antitrust Enforcement and Litigation
    (December 20, 2012)

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